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TotalEnergies SE (TTE)

Filed: 31 May 22, 12:00am

 

 

 

UNITED STATES 

SECURITIES AND EXCHANGE COMMISSION 

Washington, D.C. 20549

 

 

 

FORM SD 

Specialized Disclosure Report

 

 

 

TotalEnergies SE 

(Exact name of registrant as specified in its charter)

 

 

 

Republic of France 001-10888 98-0227345

(State or other jurisdiction of

incorporation or organization)

 

(Commission File 

Number)

 

(IRS Employer 

Identification No.)

 

2, place Jean Millier 

La Défense 6 

92400 Courbevoie 

France 

(Address of principal executive offices) (Zip Code)

 

Jean-Pierre Sbraire

Chief Financial Officer

Tel: +33 (0)1 47 44 45 46 

Fax: +33 (0)1 47 44 49 44 

(Name and telephone number, including

area code, of the person to contact in

connection with this report)

 

 

 

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

 

xRule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.
  
 Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for fiscal year ended _____________.

 

 

 

 

TotalEnergies SE is providing on this Form SD disclosure in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended.

 

Section 1 – Conflict Minerals Disclosure

 

Item 1.01(b)

 

CONFLICT MINERALS DISCLOSURE

 

TotalEnergies SE (collectively with its consolidated subsidiaries, “TotalEnergies”) is providing herein disclosure in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended, which implements reporting and disclosure requirements related to certain minerals (referred to as “conflict minerals” under the Rule) as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, for the reporting period from January 1, 2021 to December 31, 2021 (the “Reporting Period”). For the Reporting Period, “Conflict Minerals” are defined in the Rule as the following minerals (regardless of their geographic origin): cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, limited to tin, tantalum and tungsten and a “Covered Country” is defined in the Rule as the Democratic Republic of the Congo or an adjoining country.

 

This conflict minerals disclosure is also publicly available at TotalEnergies’ website:

https://totalenergies.com/sustainability/creating-shared-value/supply-chain.1

 

I.            Diligence and Reporting Process

 

TotalEnergies has established a management system to implement a diligence and reporting process concerning Conflict Minerals in accordance with the Rule. This process is coordinated at the Holding level with designated division coordinators at the level of the following business segments and operational entities (Exploration & Production, Gas, Renewables & Power, Refining & Chemicals, Trading & Shipping, Marketing & Services and TotalEnergies Global Procurement) who contact the relevant parties (such as business managers and purchasing departments). These division coordinators report the results of the diligence process to the Holding level.

 

For this Reporting Period, Saft Groupe S.A. (“Saft”), a subsidiary in the Gas, Renewables & Power business segment, Hutchinson S.A. (“Hutchinson”), a subsidiary in the Refining & Chemicals business segment, and TotalEnergies Charging Services S.A.S. (“TECS”), a subsidiary in the Marketing & Services business segment, identified products which each had manufactured, or contracted to have manufactured, that contained Conflict Minerals, namely tin, tantalum, tungsten and/or gold (collectively, “3TG”), that were necessary to the functionality or production of those products.

 

In addition, SunPower Corporation, a subsidiary in the Gas, Renewables & Power business segment based in California (“SunPower”)2, is subject to the Rule because it is an American company listed on NASDAQ. It publishes separately information concerning its use of Conflict Minerals in certain of its products that it manufactured or contracted to manufacture (solar panels, balance of systems components). The text of SunPower’s disclosure for this Reporting Period provided on its Form SD is included in Annex A to this document.

 

A. Saft is a leading manufacturer of batteries for the industrial infrastructure and processes, transportation, civil and military electronics markets, energy storage, transportation and telecommunication markets. Saft focused its diligence efforts on the suppliers of components and parts (the “Relevant Suppliers”), which were determined by Saft to contain or potentially contain 3TG, i.e., electronics and electric components, and which were incorporated into products manufactured by Saft (the “Relevant Products”).

 

With the assistance of a third party retained by it to assist with supplier outreach and data validation of the responses received from suppliers (the “Service Provider”), Saft conducted in good faith a reasonable country of origin inquiry (the “RCOI”) regarding the sourcing of the necessary Conflict Minerals, designed to determine whether any of them had originated in a Covered Country or were from recycled or scrap sources. To complete the RCOI, Saft and the Service Provider engaged the Relevant Suppliers using the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative.

 

The Relevant Suppliers had the ability to share information at a level at which they were most comfortable (i.e., company,

 

 

1 References to website in this Form SD are provided for convenience only, and their contents are not incorporated by reference into this Form SD nor deemed filed with the U.S. Securities and Exchange Commission.

2 As of December 31, 2021, TotalEnergies held 50.83% of the outstanding share capital of SunPower.

 

 

product or user-defined) but they had to specify the declaration scope. A limited number of the Relevant Suppliers replied by providing their company’s formal policy on Conflict Minerals. Both Saft and the Service Provider followed up with suppliers who did not respond to the initial request. Saft does not make purchases of raw ore or refined 3TG minerals directly from smelters or refiners. Saft’s supply chain includes many third parties between the original sources of the necessary Conflict Minerals and the products manufactured by it. Saft does not have direct contractual relationships with smelters and refiners and relies on its suppliers to provide information on the original sources of the necessary Conflict Minerals in the Relevant Products and on information provided by the Service Provider and independent third-party audit programs.

 

Based on the Relevant Suppliers’ responses, Saft could identify the potential use in their supply chain of smelters in a Covered Country. A substantial number of these smelters were in compliance with the Responsible Minerals Assurance Process Initiative assessment protocol as set forth by the RMI, without independent verification by Saft, and a small number of these smelters were identified as not conformant with this protocol, without independent verification by Saft. Based on the information provided to Saft and on Saft’s own diligence efforts, it is not possible to conclusively determine whether the necessary Conflict Mineral provided from this small number of smelters are found in a product manufactured by Saft during the Relevant Period.

 

Saft’s contracts with its suppliers require them to source responsibly, and Saft maintains an active dialogue with its suppliers on this topic. As a result, Saft does not have any reason to believe that the necessary Conflict Minerals contained in the Relevant Products in the Reporting Period directly or indirectly financed or benefitted armed groups in the Covered Countries.

 

B. Hutchinson is a global leader in vibration control, fluid management and sealing technologies. Hutchinson reached out to all of its suppliers and identified the products containing necessary Conflict Minerals during the Reporting Period: automotive fluid transfer lines, anti-vibration and sealing systems, and aerospace industrial applications (the “Hutchinson Relevant Products”), which are found in the following business activities of Hutchinson: precision sealing systems, fluid management systems, body sealing systems, anti-vibration and belt drive systems, aerospace and defense & industry.

 

Hutchinson conducted in good faith a RCOI regarding the sourcing of the necessary Conflict Minerals in the Hutchinson Relevant Products to determine whether any had originated in a Covered Country or were from recycled or scrap sources. To complete the RCOI, Hutchinson surveyed its suppliers to collect information about the presence and source of the necessary Conflict Minerals. Suppliers responded by submitting a CMRT or sending an email or letter to Hutchinson. Hutchinson followed up with suppliers who did not respond to its initial request. Hutchinson relies on the information provided to it by its suppliers.

 

Based on the suppliers’ responses, it was determined that a substantial percentage of Hutchinson’s suppliers in terms of annual turnover certified that the necessary Conflict Minerals supplied to it either originated from recycled or scrap sources or did not originate from the Covered Countries. A small percentage of suppliers in terms of annual turnover sourced necessary Conflict Minerals during the Reporting Period from one or more of the Covered Countries for the Hutchinson Relevant Products. A review of these suppliers by Hutchinson revealed them to be reputable, and mainly included major suppliers of the automotive and aerospace industries, including publicly listed companies. The small percentage of non- responsive suppliers for the Reporting Period were mainly distributors and small suppliers in terms of annual turnover.

 

The origin of some of the necessary Conflict Minerals in the Hutchinson Relevant Products could be traced to smelters that are compliant with the Responsible Minerals Assurance Process Initiative assessment protocol as set forth by the RMI, without independent verification by Hutchinson.

 

Hutchinson’s standard agreement with its suppliers require them to fill out the survey questions set forth under the CMRT and Hutchinson maintains an active dialogue with its suppliers on this topic. Hutchinson does not have any reason to believe that their necessary Conflict Minerals contained in its products in the Reporting Period directly or indirectly financed or benefitted armed groups in the Covered Countries.

 

C. TECS’ purpose is to lead the electric mobility activity within TotalEnergies. From an operational perspective, TECS ensures the development, supply, and technical support of these services and solutions including hardware, software and professional services. TECS reached out to its suppliers of components that were determined to contain or potentially contain 3TG, i.e., electronics and electric components, and which were incorporated into products manufactured by TECS (the “TECS Relevant Products”).

 

TECS conducted in good faith a RCOI regarding the sourcing of the necessary Conflict Minerals in the TECS Relevant

 

 

Products to determine whether any had originated in a Covered Country or were from recycled or scrap sources. To complete the RCOI, TECS surveyed its suppliers to collect information about the presence and source of the necessary Conflict Minerals. Suppliers responded by submitting a CMRT or sending an email or corporate policy statement letter. TECS followed up with suppliers who did not respond to its initial request. TECS relies on the information provided to it by its suppliers. TECS does not make purchases of raw ore or refined 3TG minerals directly from smelters or refiners. Its supply chain includes many third parties between the original sources of the necessary Conflict Minerals and the products manufactured by it.

 

Based on the suppliers’ responses, it was determined that substantially all suppliers had a Conflict Minerals policy within their entity. The small number of suppliers that sourced necessary Conflict Minerals during the Reporting Period from one or more of the Covered Countries are considered to be reputable, including a publicly listed company. Most of its suppliers are distributors who depend on other suppliers, and who may not maintain conflict mineral information on products that pass through their business.

 

II.            Principles

 

TotalEnergies is committed to responsible economic and social development in Africa.

 

TotalEnergies monitors responsible practices among its suppliers. In its Code of Conduct, TotalEnergies states that it works with its suppliers to ensure the protection of the interests of both parties in accordance with clear, fairly negotiated contract terms. This relationship is based on three cornerstones: dialogue, professionalism and meeting commitments.

 

TotalEnergies expects its suppliers to adhere to the Fundamental Principles of Purchasing (the “FPP”) and ensure compliance with those principles in their activities, and in particular to

 

be attentive to the day-to-day working conditions of their employees and their suppliers’ employees;
ensure that their own suppliers and subcontractors adhere to the FPP;
agree to be audited in accordance with those principles;
refer to the Ethics Committee in case of doubt.

 

The FPP, launched in 2010 and updated in early 2022, specify the commitments that TotalEnergies expects of its suppliers in the following areas3:

 

respect human rights at work;
protect health, safety and security;
act in favor of climate;
preserve the environment;
prevent corruption and conflicts of interest and fraud;
respect competition law; and
promote economic and social development.

 

An internal directive reaffirms the obligation to annex the FPP or endeavor to transpose them in the selection process as well as in the contracts concluded with suppliers of goods and services. The FPP are available for consultation by all suppliers in both French and English on TotalEnergies’ corporate website (refer to the URL provided above).

 

In addition, questionnaires focused on societal issues are used to gather more in-depth information from suppliers about their approach to such topics, either during the supplier qualification process4 or as part of an audit. TotalEnergies has also set up a supplier assessment process to identify and prevent risks of severe violations of human rights and fundamental freedoms, human health and safety. Supplier awareness-raising actions are also carried out during meetings with suppliers, particularly the Suppliers Day event that brings TotalEnergies’ strategic suppliers together every two years.

 

TotalEnergies is a member of the United Nations Global Compact platform on Decent Work in Global Supply Chains since 2018, and, in this capacity, takes part in various workshops that aim to help the member companies of the Global Compact to make progress in this area.

 

 

3 Saft and SunPower have defined fundamental principles of purchasing specific to their activities.

4 Purchases by the subsidiaries of Hutchinson, Saft and SunPower are subject to supplier qualification processes specific to their organizations.

 

 

SIGNATURES

 

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 

 TotalEnergies SE

 

Date:May 31, 2022By:  /s/ JEAN-PIERRE SBRAIRE
      Name:    Jean-Pierre SBRAIRE
      Title:     Chief Financial Officer

 

 

Annex A

 

Conflict Minerals Report

 

SunPower Corporation has included this Conflict Minerals Report as an exhibit to its Form SD for 2021 as provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”1), and Form SD (collectively, the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is May 27, 2022.

 

Unless the context indicates otherwise, the term “SunPower” refers to SunPower Corporation and its consolidated subsidiaries, and “Service Provider” refers to the third party retained by SunPower to assist with supplier outreach and data validation of the responses received from suppliers. Some of the compliance activities described in this Conflict Minerals Report were performed by the Service Provider in coordination with SunPower. As used herein and consistent with the Conflict Minerals Rule, “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals.

 

This Conflict Minerals Report can be found on the SunPower website at: http://investors.sunpower.com/sec.cfm.

 

Forward-Looking Statements

 

This document contains forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended (the “Securities Act”), and Section 21E of the Exchange Act. In particular, statements contained in this document that are not historical facts, including, but not limited to, statements concerning the additional steps that SunPower intends to take to mitigate the risk that its necessary 3TG benefit armed groups, constitute forward-looking statements and are made under the safe harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act.

 

Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties may include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by SunPower’s direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG, and (3) political, regulatory, and economic developments, whether in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”), the United States or elsewhere. SunPower cautions readers not to place undue reliance on any forward-looking statements, which only

 

 

1 Definitions provided in this Annex are exclusive to this section.

 

  

speak as of the date made. SunPower undertakes no obligation to update any forward-looking statement to reflect events or circumstances after the date on which such statement is made.

 

Overview; SunPower's Products and Applicability of the Conflict Minerals Rule

 

SunPower is a leading solar technology and energy services provider that offers fully integrated solar, storage and home energy solutions to customers primarily in the United States and Canada through an array of hardware, software, and financing options and “Smart Energy” solutions. Our Smart Energy initiative is designed to add layers of intelligent control to homes, buildings, and grids—all personalized through easy-to-use customer interfaces. SunPower products include solar panels and balance of systems components that can include inverters, combiner boxes, racking systems, mechanical and motorized systems, and electrical tracking, monitoring and controller systems. Each of the product areas that SunPower manufactures and contracts to manufacture contains 3TG necessary to the functionality or production of such products. However, 3TG content continues to represent a small portion of the materials content of SunPower’s products.

 

For a further discussion of SunPower’s products, see its Annual Report on Form 10-K for the fiscal year ended January 2, 2022. The information contained in the Form 10-K is not incorporated by reference into this Conflict Minerals Report or SunPower's Form SD for 2021 and should not be considered part of this Conflict Minerals Report or the Form SD.

 

SunPower is multiple levels removed from the mining of minerals (3TG or otherwise). SunPower does not make purchases of raw ore or refined minerals directly from smelters or refiners and makes no purchases in the Covered Countries. However, through the efforts described in this Conflict Minerals Report, SunPower seeks to ensure its suppliers are sourcing responsibly.

 

SunPower does not seek to embargo sourcing of 3TG from the Covered Countries and encourages its suppliers to continue to source 3TG responsibly from the region.

 

Reasonable Country of Origin Inquiry

 

To complete the “reasonable country of origin inquiry” (the “RCOI”) required by the Conflict Minerals Rule, SunPower and its Service Provider engaged with suppliers to collect information about the presence and source of 3TG used in products and components supplied to SunPower. For its RCOI, to the extent applicable, SunPower utilized the same processes and procedures as for its due diligence, in particular Steps 1 and 2 of the OECD Guidance (as defined below), which are discussed later in this Conflict Minerals Report. For 2021, SunPower surveyed 15 suppliers as part of its RCOI.

 

 

The results of SunPower’s RCOI are discussed under “Findings Concerning Smelters and Refiners and Country of Origin Information.”

 

Due Diligence Measures

 

Design Framework

 

SunPower utilizes due diligence measures for 3TG that are intended to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition) (the “OECD Guidance”). The OECD Guidance established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Application of the framework constitutes a part of the program that SunPower has put in place to help ensure that the 3TG contained in its products are responsibly sourced.

 

Diligence Program

 

In furtherance of SunPower’s 3TG due diligence, it performed the due diligence measures discussed below for 2021.

 

Compliance Team

 

In support of its compliance efforts, SunPower has a compliance team that is charged with overseeing, implementing and providing feedback on its 3TG compliance strategy. The team consists of staff from SunPower’s operations groups, under executive leadership. The members of the team and selected other internal personnel are expected to be familiar with the Conflict Minerals Rule, the OECD Guidance, SunPower’s compliance plan, and the procedures for reviewing and validating supplier responses to SunPower’s inquiries. SunPower also utilized the Service Provider and specialist outside counsel to assist with and/or to advise it on certain aspects of its compliance.

 

Conflict Minerals Policy; Training Resources; Grievance Mechanism

 

SunPower maintains a Conflict Minerals Policy. Under the Conflict Minerals Policy, SunPower suppliers are required to acknowledge SunPower’s Supplier Sustainability Guidelines, which incorporates the Conflict Minerals Policy. Under the Conflict Minerals Policy, SunPower reserves the right to request additional documentation from its suppliers regarding the source of any 3TG included in their products. In addition, SunPower reserves the right to ask suppliers to maintain traceability data for a minimum of five years. The Conflict Minerals Policy indicates

 

 

that SunPower will evaluate its relationships with its suppliers on an ongoing basis to ensure continued compliance with the Conflict Minerals Policy.

 

The Conflict Minerals Policy is communicated internally to SunPower’s supply chain employees and to suppliers. In addition, the Conflict Minerals Policy is posted on SunPower’s website at https://us.sunpower.com/sites/default/files/media-library/compliance-briefs/cb-sunpower-conflict-minerals-policy.pdf.

 

In an effort to increase supplier awareness about Conflict Minerals and related regulatory requirements, provide answers to frequently asked questions concerning 3TG mineral tracing, and ultimately improve the accuracy and completeness of supplier responses, suppliers that were part of SunPower’s outreach received access to the Service Provider’s online resources.

 

SunPower has a grievance mechanism for reporting violations of its Conflict Minerals Policy. The grievance mechanism is available through the Conflict Minerals Policy. Violations may be reported by calling SunPower’s Compliance and Ethics Helpline at 1-866-307-5679 within the United States, or at toll-free numbers provided for additional countries/regions in SunPower’s Code of Business Conduct and Ethics available on its investor relations website at investors.sunpower.com, or by going to SunPower’s reporting website at sunpower.alertline.com.

 

Data Collection; Records Storage and Retention

 

For 2021, SunPower carried out due diligence on parts selected by SunPower within the bills of materials of products that were contracted to be manufactured, based on supplier spend. The contract manufacturers carried out due diligence for general use parts of products that were contracted to be manufactured, the results of which were reflected in their Conflict Minerals Reporting Templates (collectively, the “CMRTs” and individually, a “CMRT”) furnished to SunPower. SunPower’s outreach included 15 suppliers (the “Suppliers”) that (1) contracted to manufacture products for SunPower which were determined by SunPower to contain or potentially contain 3TG which is necessary to the functionality or production of the products, or (2) provided components, parts, or products which were determined by SunPower to contain or potentially contain necessary 3TG, and which were incorporated into products contracted to be manufactured by SunPower.

 

SunPower sent the Suppliers a request to submit a CMRT to gather information on the use of 3TG by the Suppliers, the source of the 3TG and the Suppliers’ related compliance procedures. SunPower gave the Suppliers the ability to provide information at a level at which they could most readily assemble the information (i.e., company, product, or user-defined), but required the Suppliers to declare the level of information provided. Following the initial introductions to the

 

 

program and information request, up to three reminder emails were sent to each non-responsive Supplier requesting survey completion. This outreach was managed by the Service Provider on our behalf. Additional outreach also was conducted by SunPower’s staff on an as-needed basis to further emphasize the importance of suppliers completing the CMRT.

 

The Service Provider reviewed CMRT responses received from the Suppliers for incomplete responses, potential errors or inaccuracies, lack of consistency, and other flags. If any “quality control” flags were raised, Suppliers were contacted to clarify the concern. If a smelter or refiner was not on the CMRT Smelter Look-up tab list, the Service Provider (a) requested that the Supplier confirm that the listed entity was a smelter or refiner, (b) consulted publicly-available information to attempt to determine whether the identified entity was a smelter or refiner, or (c) attempted to contact the listed entity. If the smelter or refiner was not identified as Conformant (as later defined) or the equivalent by the Responsible Minerals Initiative (the “RMI”), the London Bullion Market Association (the “LMBA”) or the Responsible Jewellery Council (the “RJC”), SunPower or the Service Provider attempted to contact the smelter or refiner to gain more information about its sourcing practices, including countries of origin and transfer, and due diligence procedures.

 

To the extent that no contact was made with a smelter or refiner identified by a Supplier, SunPower or the Service Provider searched public information to attempt to determine the mine or location of origin of the 3TG processed by the smelter or refiner and whether it obtains 3TG from sources that directly or indirectly finance or benefit armed groups in a Covered Country.

 

SunPower has an electronic file for the maintenance of business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions. SunPower stores all supplier CMRTs and documents evidence of identified supplier 3TG sourcing risk. As contemplated by the OECD Guidance, SunPower will maintain these records for at least five years. The Service Provider also has been requested to maintain records in its possession for at least five years.

 

3TG Risk Management

 

SunPower obtained information on 3TG sourcing risk from the Service Provider. SunPower further used the CMRT responses to identify 3TG sourcing risk. Given SunPower’s position in the 3TG supply chain, it believes that this is the most efficient means for identifying 3TG sourcing risk.

 

The quality and supply chain teams within SunPower worked together to identify 3TG sourcing concerns and determine risk mitigation efforts. The quality team reported aggregated risk

 

 

findings to and the contents of this Conflict Minerals Report are shared with SunPower’s executive management.

 

SunPower determines on a case-by-case basis the appropriate risk mitigation strategy for any identified risks. Potential outcomes under SunPower’s risk mitigation strategy include continuing to work with the supplier while risks are addressed or reassessing the relationship with the supplier. Under SunPower’s risk management framework, to the extent that risks require mitigation, SunPower monitors and tracks the performance of the risk mitigation efforts and reports these efforts to appropriate senior oversight personnel.

 

Utilization of Independent Third-Party Audits

 

To the extent that smelters or refiners are identified, SunPower primarily utilizes information made available by the RMI concerning independent third-party audits and Conformant status. SunPower also relies on audits performed by the LBMA and the RJC.

 

Report on Supply Chain Due Diligence

 

SunPower files a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission and makes these filings available on its investor relations website.

 

Findings Concerning Smelters and Refiners and Country of Origin Information

 

For 2021, SunPower surveyed 15 suppliers as part of its 3TG due diligence and received 15 CMRTs in response to its outreach. The CMRT declarations received identified 329 smelters and refiners that processed or may have processed 3TG contained in SunPower’s products. Of these 15 CMRT declarations, 12 were company-level, 3 were product-level, and 0 were at a level defined by the Supplier. Due to the number of Suppliers providing company-level declarations, the list of processing facilities disclosed below may over-represent the number of 3TG processing facilities in SunPower’s supply chain.

 

In brief, as indicated in the table below:

 

329 smelters and refiners were identified by the Suppliers.

227 smelters and refiners, or 69%, were listed as Conformant by the RMI.

17 smelters or refiners, or 5%, were listed as Active.

85 smelters or refiners, or 26%, were listed on the CMRT Smelter Look-up tab only.

 

In connection with SunPower’s RCOI or due diligence, as applicable, the Suppliers identified to SunPower the facilities listed below as potentially having processed the necessary 3TG contained in SunPower’s in-scope products in 2021 (table information is as of May 11, 2022; see the notes following the table for additional information concerning the information presented in the table).

 

 

MetalSmelter NameCountry NameStatus
Gold8853 S.p.A.ItalyConformant
GoldAbington Reldan Metals, LLCUnited StatesActive
GoldAdvanced Chemical CompanyUnited StatesConformant
GoldAfrican Gold RefineryUgandaOn Smelter Look-up Tab Only
GoldAida Chemical Industries Co., Ltd.JapanConformant
GoldAl Etihad Gold Refinery DMCCUnited Arab EmiratesConformant
GoldAlexy MetalsUnited StatesActive
GoldAgosi AGGermanyConformant
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UzbekistanConformant
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazilConformant
GoldArgor-Heraeus S.A.SwitzerlandConformant
GoldAsahi Pretec Corp.JapanConformant
GoldAsahi Refining Canada Ltd.CanadaConformant
GoldAsahi Refining USA Inc.United StatesConformant
GoldAsaka Riken Co., Ltd.JapanConformant
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TurkeyOn Smelter Look-up Tab Only
GoldAU Traders and RefinersSouth AfricaOn Smelter Look-up Tab Only
GoldAugmont Enterprises Private LimitedIndiaActive

 

 

 

 

GoldAurubis AGGermanyConformant
GoldBangalore RefineryIndiaOn Smelter Look-up Tab Only
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PhilippinesConformant
GoldBoliden ABSwedenConformant
GoldC. Hafner GmbH + Co. KGGermanyConformant
GoldC.I Metales Procesados Industriales SASColombiaActive
GoldCaridadMexicoOn Smelter Look-up Tab Only
GoldCCR Refinery - Glencore Canada CorporationCanadaConformant
GoldCendres + Metaux S.A.SwitzerlandConformant
GoldCGR Metalloys Pvt Ltd.IndiaOn Smelter Look-up Tab Only
GoldChimet S.p.A.ItalyConformant
GoldChugai MiningJapanConformant
GoldDaye Non-Ferrous Metals Mining Ltd.ChinaOn Smelter Look-up Tab Only
GoldDegussa Sonne / Mond Goldhandel GmbHGermanyOn Smelter Look-up Tab Only
GoldDijllah Gold Refinery FZCUnited Arab EmiratesOn Smelter Look-up Tab Only
GoldDODUCO Contacts and Refining GmbHGermanyConformant

 

 

 

 

GoldDowaJapanConformant
GoldDSC (Do Sung Corporation)KoreaConformant
GoldEco-System Recycling Co., Ltd. East PlantJapanConformant
GoldEco-System Recycling Co., Ltd. North PlantJapanConformant
GoldEco-System Recycling Co., Ltd. West PlantJapanConformant
GoldEmerald Jewel Industry India Limited (Unit 1)IndiaOn Smelter Look-up Tab Only
GoldEmerald Jewel Industry India Limited (Uni 2)IndiaOn Smelter Look-up Tab Only
GoldEmerald Jewel Industry India Limited (Unit 3)IndiaOn Smelter Look-up Tab Only
GoldEmerald Jewel Industry India Limited (Unit 4)IndiaOn Smelter Look-up Tab Only
GoldEmirates Gold DMCCUnited Arab EmiratesConformant
GoldFidelity Printers and Refiners Ltd.ZimbabweOn Smelter Look-up Tab Only
GoldFujairah Gold FZCUnited Arab EmiratesOn Smelter Look-up Tab Only
GoldGGC Gujrat Gold Centre Pvt. Ltd.IndiaActive
GoldGeib Refining CorporationUnited StatesConformant
GoldGold Coast RefineryGhanaOn Smelter Look-up Tab Only

 

 

 

  

GoldGold Refinery of Zijin Mining Group Co., Ltd.ChinaConformant
GoldGreat Wall Precious Metals Co., Ltd. of CBPMChinaOn Smelter Look-up Tab Only
GoldGuangdong Jinding Gold LimitedChinaOn Smelter Look-up Tab Only
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldHangzhou Fuchunjiang Smelting Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldHeimerle + Meule GmbHGermanyConformant
GoldHeraeus Metals Hong Kong Ltd.ChinaConformant
GoldHeraeus Precious Metals GmbH & Co. KGGermanyConformant
GoldHunan Chenzhou Mining Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldHwaSeong CJ CO., LTD.KoreaOn Smelter Look-up Tab Only
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.ChinaConformant
GoldInternational Precious Metal RefinersUnited Arab EmiratesOn Smelter Look-up Tab Only
GoldIshifuku Metal Industry Co., Ltd.JapanConformant
GoldIstanbul Gold RefineryTurkeyConformant
GoldItalpreziosiItalyConformant

 

 

 

  

GoldJALAN & CompanyIndiaOn Smelter Look-up Tab Only
GoldJapan MintJapanConformant
GoldJiangxi Copper Co., Ltd.ChinaConformant
GoldJSC UralelectromedRussian FederationOn Smelter Look-up Tab Only
GoldJX Nippon Mining & Metals Co., Ltd.JapanConformant
GoldK.A. RasmussenNorwayOn Smelter Look-up Tab Only
GoldKaloti Precious MetalsUnited Arab EmiratesOn Smelter Look-up Tab Only
GoldKazakhmys Smelting LLCKazakhstanOn Smelter Look-up Tab Only
GoldKazzincKazakhstanConformant
GoldKennecott Utah Copper LLCUnited StatesConformant
GoldKGHM Polska Miedz Spolka AkcyjnaPolandConformant
GoldKojima Chemicals Co., Ltd.JapanConformant
GoldKorea Zinc Co., Ltd.KoreaConformant
GoldKundan Care Products Ltd.IndiaOn Smelter Look-up Tab Only
GoldKyrgyzaltyn JSCKyrgyzstanOn Smelter Look-up Tab Only
GoldKyshtym Copper-Electrolytic Plant ZAORussian FederationOn Smelter Look-up Tab Only

 

 

 

 

GoldL'azurde Company For JewelrySaudi ArabiaOn Smelter Look-up Tab Only
GoldL'Orfebre S.A.AndorraConformant
GoldLingbao Gold Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldLS-NIKKO Copper Inc.KoreaConformant
GoldLT Metal Ltd.KoreaConformant
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldMarsam MetalsBrazilConformant
GoldMaterionUnited StatesConformant
GoldMatsuda Sangyo Co., Ltd.JapanConformant
GoldMD OverseasIndiaOn Smelter Look-up Tab Only
GoldMetal Concentrators SA (Pty) Ltd.South AfricaConformant
GoldMetallix Refining Inc.United StatesOn Smelter Look-up Tab Only
GoldMetalor Technologies (Hong Kong) Ltd.ChinaConformant
GoldMetalor Technologies (Singapore) Pte., Ltd.SingaporeConformant
GoldMetalor Technologies (Suzhou) Ltd.ChinaConformant
GoldMetalor Technologies S.A.SwitzerlandConformant

 

 

 

  

GoldMetalor USA Refining CorporationUnited StatesConformant
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MexicoConformant
GoldMitsubishi Materials CorporationJapanConformant
GoldMitsui Mining and Smelting Co., Ltd.JapanConformant
GoldMMTC-PAMP India Pvt., Ltd.IndiaConformant
GoldModeltech Sdn BhdMalaysiaOn Smelter Look-up Tab Only
GoldMorris and WatsonNew ZealandOn Smelter Look-up Tab Only
GoldMoscow Special Alloys Processing PlantRussian FederationOn Smelter Look-up Tab Only
GoldNadir Metal Rafineri San. Ve Tic. A.S.TurkeyConformant
GoldNavoi Mining and Metallurgical CombinatUzbekistanConformant
GoldNH Recytech CompanyKoreaConformant
GoldNihon Material Co., Ltd.JapanConformant
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustriaConformant
GoldOhura Precious Metal Industry Co., Ltd.JapanConformant
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)Russian FederationOn Smelter Look-up Tab Only

 

 

 

  

GoldOJSC Novosibirsk RefineryRussian FederationOn Smelter Look-up Tab Only
GoldPAMP S.A.SwitzerlandConformant
GoldPease & CurrenUnited StatesOn Smelter Look-up Tab Only
GoldPenglai Penggang Gold Industry Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldPlanta Recuperadora de Metales SpAChileConformant
GoldPrioksky Plant of Non-Ferrous MetalsRussian FederationOn Smelter Look-up Tab Only
GoldPT Aneka Tambang (Persero) TbkIndonesiaConformant
GoldPX Precinox S.A.SwitzerlandConformant
GoldQG Refining, LLCUnited StatesOn Smelter Look-up Tab Only
GoldRand Refinery (Pty) Ltd.South AfricaConformant
GoldRefinery of Seemine Gold Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldREMONDIS PMR B.V.NetherlandsConformant
GoldRoyal Canadian MintCanadaConformant
GoldSAAMPFranceConformant
GoldSabin Metal Corp.United StatesOn Smelter Look-up Tab Only
GoldSafimet S.p.AItalyConformant
GoldSAFINA A.S.Czech RepublicConformant

 

 

 

 

GoldSai RefineryIndiaOn Smelter Look-up Tab Only
GoldSamduck Precious MetalsKoreaConformant
GoldSAMWON METALS Corp.KoreaOn Smelter Look-up Tab Only
GoldSancus ZFS (L’Orfebre, SA)ColombiaActive
GoldSAXONIA Edelmetalle GmbHGermanyOn Smelter Look-up Tab Only
GoldSellem Industries Ltd.MauritaniaOn Smelter Look-up Tab Only
GoldSEMPSA Joyeria Plateria S.A.SpainConformant
GoldShandong Humon Smelting Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.ChinaConformant
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldShirpur Gold Refinery Ltd.IndiaOn Smelter Look-up Tab Only
GoldSichuan Tianze Precious Metals Co., Ltd.ChinaConformant
GoldSingway Technology Co., Ltd.TaiwanConformant
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussian FederationOn Smelter Look-up Tab Only

 

 

 

 

GoldSolar Applied Materials Technology Corp.TaiwanConformant
GoldSovereign MetalsIndiaOn Smelter Look-up Tab Only
GoldState Research Institute Center for Physical Sciences and TechnologyLithuaniaOn Smelter Look-up Tab Only
GoldSudan Gold RefinerySudanOn Smelter Look-up Tab Only
GoldSumitomo Metal Mining Co., Ltd.JapanConformant
GoldSungEel HiMetal Co., Ltd.KoreaConformant
GoldT.C.A S.p.AItalyConformant
GoldTanaka Kikinzoku Kogyo K.K.JapanConformant
GoldThe Refinery of Shandong Gold Mining Co., Ltd.ChinaConformant
GoldTokuriki Honten Co., Ltd.JapanConformant
GoldTongling Nonferrous Metals Group Co., Ltd.ChinaConformant
GoldTOO Tau-Ken-AltynKazakhstanConformant
GoldTorecomKoreaConformant
GoldUmicore Precious Metals ThailandThailandConformant
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgiumConformant
GoldUnited Precious Metal Refining, Inc.United StatesConformant
GoldValcambi S.A.SwitzerlandConformant

 

 

 

 

GoldValue TradingBelgiumOn Smelter Look-up Tab Only
GoldWeeerefiningFranceActive
GoldWestern Australian Mint (T/a The Perth Mint)AustraliaConformant
GoldWIELAND Edelmetalle GmbHGermanyConformant
GoldYamakin Co., Ltd.JapanConformant
GoldYokohama Metal Co., Ltd.JapanConformant
GoldYunnan Copper Industry Co., Ltd.ChinaOn Smelter Look-up Tab Only
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChinaConformant
TantalumChangsha South Tantalum Niobium Co., Ltd.ChinaConformant
TantalumD Block Metals, LLCUnited StatesConformant
TantalumExotech Inc.United StatesOn Smelter Look-up Tab Only
TantalumF&X Electro-Materials Ltd.ChinaConformant
TantalumFIR Metals & Resource Ltd.ChinaConformant
TantalumGlobal Advanced Metals AizuJapanConformant
TantalumGlobal Advanced Metals BoyertownUnited StatesConformant
TantalumH.C. Starck Hermsdorf GmbHGermanyConformant
TantalumH.C. Starck Inc.United StatesConformant

 

 

 

 

TantalumHengyang King Xing Lifeng New Materials Co., Ltd.ChinaConformant
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.ChinaConformant
TantalumJiangxi Tuohong New Raw MaterialChinaConformant
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.ChinaConformant
TantalumJiujiang Tanbre Co., Ltd.ChinaConformant
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.ChinaConformant
TantalumKEMET Blue MetalsMexicoConformant
TantalumLSM Brasil S.A.BrazilConformant
TantalumMetallurgical Products India Pvt., Ltd.IndiaConformant
TantalumMineracao Taboca S.A.BrazilConformant
TantalumMitsui Mining and Smelting Co., Ltd.JapanConformant
TantalumNingxia Orient Tantalum Industry Co., Ltd.ChinaConformant
TantalumNPM Silmet ASEstoniaConformant
TantalumQuantumCleanUnited StatesConformant
TantalumResind Industria e Comercio Ltda.BrazilConformant
TantalumSolikamsk Magnesium Works OAORussian FederationOn Smelter Look-up Tab Only
TantalumTaki Chemical Co., Ltd.JapanConformant

 

 

 

  

TantalumTANIOBIS Co., Ltd.ThailandConformant
TantalumTANIOBIS GmbHGermanyConformant
TantalumTANIOBIS Japan Co., Ltd.JapanConformant
TantalumTANIOBIS Smelting GmbH & Co. KGGermanyConformant
TantalumTelex MetalsUnited StatesConformant
TantalumUlba Metallurgical Plant JSCKazakhstanConformant
Tantalum Ximei Resources (Guangdong) LimitedChinaConformant
TantalumXinXing Haorong Electronic Material Co., Ltd.ChinaConformant
TantalumYancheng Jinye New Material Technology Co., Ltd.ChinaConformant
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.ChinaConformant
TinAlphaUnited StatesConformant
TinAn Vinh Joint Stock Mineral Processing CompanyVietnamOn Smelter Look-up Tab Only
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.ChinaConformant
TinChifeng Dajingzi Tin Industry Co., Ltd.ChinaConformant
TinChina Tin Group Co., Ltd.ChinaConformant
TinCRM Fundicao De Me Metais E Comercio De Equipamentos Electronicos Do Brasil LtdaBrazilActive

 

 

 

 

TinCRM SynergiesSpainConformant
TinCV Venus Inti PerkasaIndonesiaActive
TinDongguan CiEXPO Environmental Engineering Co., Ltd.ChinaOn Smelter Look-up Tab Only
TinDowaJapanConformant
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVietnamOn Smelter Look-up Tab Only
TinEM VintoBoliviaConformant
TinEstanho de Rondonia S.A.BrazilConformant
TinFabrica Auricchio Industria e Comercio Ltda.BrazilConformant
TinFenix MetalsPolandConformant
TinGejiu City Fuxiang Industry and Trade Co., Ltd.ChinaOn Smelter Look-up Tab Only
TinGejiu Kai Meng Industry and Trade LLCChinaOn Smelter Look-up Tab Only
TinGejiu Non-Ferrous Metal Processing Co., Ltd.ChinaConformant
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.ChinaConformant
TinGejiu Zili Mining And Metallurgy Co., Ltd.ChinaConformant
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.ChinaConformant

 

 

 

 

TinHuiChang Hill Tin Industry Co., Ltd.ChinaConformant
TinJiangxi New Nanshan Technology Ltd.ChinaConformant
TinLuna Smelter, Ltd.RwandaConformant
TinMa'anshan Weitai Tin Co., Ltd.ChinaConformant
TinMagnu's Minerais Metais e Ligas Ltda.BrazilConformant
TinMalaysia Smelting Corporation (MSC)MalaysiaConformant
TinMelt Metais e Ligas S.A.BrazilOn Smelter Look-up Tab Only
TinMetallic Resources, Inc.United StatesConformant
TinMetallo Belgium N.V.BelgiumConformant
TinMetallo Spain S.L.U.SpainConformant
TinMineracao Taboca S.A.BrazilConformant
TinMinsurPeruConformant
TinMitsubishi Materials CorporationJapanConformant
TinModeltech Sdn BhdMalaysiaOn Smelter Look-up Tab Only
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVietnamOn Smelter Look-up Tab Only
TinO.M. Manufacturing (Thailand) Co., Ltd.ThailandConformant
TinO.M. Manufacturing Philippines, Inc.PhilippinesConformant

 

 

 

 

TinOperaciones Metalurgicas S.A.BoliviaConformant
TinPongpipat Company LimitedMyanmarOn Smelter Look-up Tab Only
TinPrecious Minerals and Smelting LimitedIndiaOn Smelter Look-up Tab Only
TinPT Aries Kencana SejahteraIndonesiaActive
TinPT Artha Cipta LanggengIndonesiaConformant
TinPT ATD Makmur Mandiri JayaIndonesiaConformant
TinPT Babel Inti PerkasaIndonesiaConformant
TinPT Babel Surya Alam LestariIndonesiaConformant
TinPT Bangka SerumpunIndonesiaConformant
TinPT Bukit TimahIndonesiaConformant
TinPT Cipta Persada MuliaIndonesiaConformant
TinPT Masbro Alam StaniaIndonesiaActive
TinPT Menara Cipta MuliaIndonesiaConformant
TinPT Mitra Stania PrimaIndonesiaConformant
TinPT Mitra Sukses GlobalindoIndonesiaActive
TinPT Prima Timah UtamaIndonesiaConformant
TinPT Rajawali Rimba PerkasaIndonesiaConformant
TinPT Refined Bangka TinIndonesiaConformant
TinPT Sariwiguna BinasentosaIndonesiaConformant
TinPT Stanindo Inti PerkasaIndonesiaConformant
TinPT Sukses Inti MakmurIndonesiaActive

 

 

 

 

TinPT Timah NusantaraIndonesiaActive
TinPT Timah Tbk KundurIndonesiaConformant
TinPT Timah Tbk MentokIndonesiaConformant
TinTinindo Inter NusaIndonesiaConformant
TinResind Industria e Comercio Ltda.BrazilConformant
TinRui Da HungTaiwanConformant
TinSoft Metais Ltda.BrazilConformant
TinSuper LigasBrazilActive
TinThai Nguyen Mining and Metallurgy Co., Ltd.VietnamConformant
TinThaisarcoThailandConformant
TinTin Technology & RefiningUnited StatesConformant
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVietnamOn Smelter Look-up Tab Only
TinVQB Mineral and Trading Group JSCVietnamOn Smelter Look-up Tab Only
TinWhite Solder Metalurgia e Mineracao Ltda.BrazilConformant
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.ChinaConformant
TinTin Smelting Branch of Yunnan Tin Co., Ltd.ChinaConformant
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.ChinaOn Smelter Look-up Tab Only
TungstenA.L.M.T. TUNGSTEN Corp.JapanConformant

 

 

 

 

TungstenACL Metais EireliBrazilConformant
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BrazilActive
TungstenArtek LLCRussian FederationOn Smelter Look-up Tab Only
TungstenAsia Tungsten Products Vietnam Ltd.VietnamConformant
TungstenChina Molybdenum Co., Ltd.ChinaConformant
TungstenChongyi Zhangyuan Tungsten Co., Ltd.ChinaConformant
TungstenCNMC (Guangxi) PGMA Co., Ltd.ChinaOn Smelter Look-up Tab Only
TungstenCronimet Brasil LtdaBrazilConformant
TungstenFujian Ganmin RareMetal Co., Ltd.ChinaConformant
TungstenFujian Xinlu TungstenChinaConformant
TungstenGanzhou Haichuang Tungsten Co., Ltd.ChinaConformant
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.ChinaConformant
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.ChinaConformant
TungstenGanzhou Seadragon W & Mo Co., Ltd.ChinaConformant
TungstenGlobal Tungsten & Powders Corp.United StatesConformant
TungstenGuangdong Xianglu Tungsten Co., Ltd.ChinaConformant

 

 

 

 

TungstenH.C. Starck Tungsten GmbHGermanyConformant
TungstenHubei Green Tungsten Co., Ltd.ChinaConformant
TungstenHunan Chenzhou Mining Co., Ltd.ChinaConformant
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.ChinaConformant
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchChinaConformant
TungstenHydrometallurg, JSCRussian FederationOn Smelter Look-up Tab Only
TungstenJapan New Metals Co., Ltd.JapanConformant
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.ChinaConformant
TungstenJiangxi Gan Bei Tungsten Co., Ltd.ChinaConformant
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.ChinaOn Smelter Look-up Tab Only
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.ChinaConformant
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.ChinaConformant
TungstenJiangxi Yaosheng Tungsten Co., Ltd.ChinaConformant
TungstenJSC "Kirovgrad Hard Alloys Plant"Russian FederationOn Smelter Look-up Tab Only
TungstenKennametal FallonUnited StatesConformant
TungstenKennametal HuntsvilleUnited StatesConformant

 

 

 

 

TungstenKGETS CO., LTD.KoreaConformant
TungstenLianyou Metals Co., Ltd.TaiwanConformant
TungstenMalipo Haiyu Tungsten Co., Ltd.ChinaConformant
TungstenMasan Tungsten Chemical LLC (MTC)VietnamConformant
TungstenMoliren Ltd.Russian FederationOn Smelter Look-up Tab Only
TungstenNiagara Refining LLCUnited StatesConformant
TungstenNPP Tyazhmetprom LLCRussian FederationActive
TungstenPhilippine Chuangxin Industrial Co., Inc.PhilippinesConformant
TungstenTANIOBIS Smelting GmbH & Co. KGGermanyConformant
TungstenUnecha Refractory Metals PlantRussian FederationOn Smelter Look-up Tab Only
TungstenWolfram Bergbau und Hutten AGAustriaConformant
TungstenXiamen Tungsten (H.C.) Co., Ltd.ChinaConformant
TungstenXiamen Tungsten Co., Ltd.ChinaConformant
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.ChinaConformant

 

a)“Conformant” means that a smelter or refiner has successfully completed an assessment against the applicable Responsible Minerals Assurance Process (“RMAP”) standard or an equivalent cross-recognized assessment. Included smelters and refiners were not necessarily Conformant for all or part of 2021 and may not continue to be Conformant for any future period.

 

b)“Active” means that a smelter or refiner is currently engaged in the RMAP but a conformance determination has yet to be made.

 

 

 

 

c)“On Smelter Look-up Tab Only” means that a smelter or refiner is listed on the Smelter Look-up tab list of the CMRT, but is not listed as “Conformant” or “Active.” The RMI notes on its website that the operational impacts of COVID-19 have led to postponements of some RMAP assessments. The RMI website also notes that, due to the eligibility criteria for an RMAP assessment, smelters are sometimes removed from the Conformant list because they are no longer operational and not because they are non-conformant to the standard.

 

d)Smelter or refiner status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by SunPower.

 

e)Country location is the location of the smelter or refiner and is based solely on information made publicly available by the RMI, without independent verification by SunPower.

 

Country of Origin Information

 

SunPower has endeavored to determine the mine or location of origin of the necessary 3TG contained in its in-scope products by requiring that the Suppliers provide it with completed CMRTs and through the other measures described in this Conflict Minerals Report. Where a smelter or refiner has been identified that is not Conformant, SunPower or the Service Provider also has reviewed public information, to the extent available, to try to determine the mine or location of origin of the 3TG processed by the smelter or refiner.

 

The countries of origin of the newly-mined 3TG processed by smelters and refiners listed above may have included countries listed below (as well as possibly other countries).

 

AngolaFinlandMadagascarSouth Sudan
ArgentinaFranceMalaysiaSpain
ArmeniaGermanyMaliSuriname
AustriaGhanaMexicoSweden
BelgiumGuineaMongoliaSwitzerland
BermudaGuyanaMozambiqueTaiwan
BoliviaHong KongMyanmarTajikistan
BrazilHungaryNamibiaTanzania*
Burundi*IndiaNetherlandsThailand
CambodiaIndonesiaNigerTurkey
CanadaIrelandNigeriaUnited Arab Emirates
Central African RepublicIsraelPapua New GuineaUnited Kingdom
ChileItalyPeruUnited States
ChinaIvory CoastPhilippinesUzbekistan
ColombiaJapanPolandVietnam
Czech RepublicJerseyPortugalZambia*
DjiboutiKazakhstanRussian FederationZimbabwe

 

 

 

 

Democratic Republic of the Congo*KenyaRwanda* 
EcuadorKoreaSierra Leone 
EgyptKyrgyzstanSingapore 
EstoniaLaosSlovakia 
EthiopiaLuxembourgSouth Africa 

 

* Represents a Covered Country.

 

The 3TG processed by the identified smelters and refiners also may have originated in whole or in part from recycled or scrap sources.

 

Due Diligence Improvement Measures

 

SunPower intends to further improve its due diligence measures for 2022 in order to mitigate the risk that the necessary 3TG in its in-scope products benefit armed groups by taking the following steps, among others:

 

·Continue to alert suppliers when SunPower obtains information that a 3TG smelter or refiner is believed to be irresponsibly sourcing 3TG.

·Request that suppliers who have identified non-Conformant or high-risk smelters require their upstream suppliers to find alternative sources of 3TG or require certification of the smelters and refiners in their supply chains.

·Review our 3TG compliance program for potential additional enhancements, in particular ways to enhance supplier engagement.

 

The foregoing steps are in addition to the steps that SunPower took for 2021.